What are the key points of the food additive “ carryover principle”?

The concept of “carry-in principle” was first introduced in the national standard GB 2760-2007. Carry-over can be understood as a certain level of a food additive detected in a food, but the additive is not directly added to the food, but with other food containing the food additive raw materials (ingredients) to bring in, but this carry-over must be scientific and reasonable.
In addition, with the development of the food industry, the upstream and downstream specialization and matching of the food production and processing industry is getting higher and higher, and the food raw materials and auxiliaries industry, according to the needs of the food end-product industry, sometimes adds food additives that are allowed to be used in the end-products in the food ingredients that are “customized” for the food end-products. In other words, the food additives used do not play a role in the raw materials of the food, but rather in the final product, which is a very common practice in the food industry.
In order to meet the development of the food industry and the needs of food supervision, the GB2760-2014 Edition not only contains the carry-over principle (3.4.1) firstly proposed in the 2007 Edition, but also improves and revises other related contents of the carry-over principle with reference to the relevant international standards, and adds the contents of 3.4.2 in the main part of 3.4 Carry-over Principle of the GB2760-2014 Standard. In order to promote industry practitioners, food safety supervisors and food inspectors to better understand the carry-over principle of GB2760, and apply the carry-over principle of food additives more rigorously and scientifically, this paper will focus on the “ingredient carry-over” and “background carry-over” of food additives [1]. This paper will focus on the “ingredient carryover” and “background carryover” of food additives [6]. Ingredient carry-over

I. Article 3.4.1 of GB2760-2014 Some food products are not allowed to use certain food additives in accordance with the provisions of GB2760-2014, but due to the addition of certain food ingredients or auxiliary materials added in the process of food processing itself added to the permitted varieties of the above food additives, when the amount of food additives with food additives added to the finished food products reaches a certain level, the carry-in food additives will be detected [7]. additives are detected will be greatly increased.
According to Article 3.4.1 of GB2760-2014, food additives shall be allowed to be carried into food through food ingredients (including food additives) when applicable (conditions a, b, c and d of Article 3.4.1 of GB2760-2014 shall be complied with at the same time). It is worth noting that the carry-over situation in this article should be carried over under normal production process conditions and the level of food additives carried over into the final product should not exceed the level carried over from the ingredients. If a preservative is intentionally added in large quantities to the ingredients used in the final product in order to make the final product achieve anticorrosive antimicrobial effect and prolong the shelf-life or if an ingredient not necessary for the process is intentionally used for the final food in the capacity as the carrier of the preservative, i.e., if the use of the preservative in the ingredients is intended to be used in the final food, it is not allowed to carry over the preservative into the final food. The use of a preservative in an ingredient for the purpose of performing a functional role in the final product does not comply with Carry-over Principle 3.4.1.
Therefore, manufacturers should focus on the quality of food ingredients or excipients during production and processing, and be aware of which food additives are used in the ingredients to prevent the use of unqualified food ingredients; and testing organizations should also investigate the possibility of carry-over of food additives in food ingredients when a class of food additives is detected. The following table lists several situations in which carry-over Principle 3.4.1 is possible. See Table 1

Article 3.4.2 of GB2760-2014 This article is a new article added to the 2014 version of GB 2760, and is brought into Principle 3.4.2, which is aimed at the practice of adding food additives used in end products to food ingredients that are “tailor-made” for the end products of food products, due to the needs of the development of the food industry and the increasing specialization and matching of the upstream and downstream of the food processing industry. Due to the development needs of the food industry and the increasing specialization and matching between the upstream and downstream of the food processing industry, such practice is very common in the food industry.
The food additives added in food ingredients as stipulated in this article are intended to play a process role in specific end products, not to play a process role in food ingredients, and the added food additives must be the varieties permitted to be used in the end products of the food by GB2760, and the amount of such food additives used in food ingredients should be guaranteed so that the amount in the end products of the food cannot exceed the amount stipulated in GB2760 [1]. and the amount of this food additive used in the food ingredient shall be guaranteed so that its amount in the food end product shall not exceed the provisions of GB2760 [1].
Food ingredients to which the above food additives have been added can only be used as raw materials for specific food end-products, and the labeling must clearly identify that the food ingredients are used in the production of specific food end-products. The following table lists several situations in which Principle 3.4.2 may be carried over. See Table 2

III. Comparison of Principles 3.4.1 and 3.4.2 Principles 3.4.1 and 3.4.2 Although both principles provide for the introduction of food additives from ingredients into the final product of a food, there is a significant difference between the two, which is illustrated in the following table: see Table 3.

Background introduction
Some other foods or food raw materials are not added with certain food additives or certain types of chemical substances, but they are detected in the final products, which may be caused by the background introduction of these foods or food raw materials. Intrinsically introduced food additives, contaminants or banned substances may originate from the natural existence of the food raw materials themselves, or from environmental pollution, contamination of raw and auxiliary materials, migration of packaging materials, or due to metabolism during animal and plant growth, or microbial metabolism during food processing (e.g., fermentation process).
Under the action of one or more factors from the above sources, it may lead to a certain amount of specific food additives, contaminants or banned substance ingredients in the terminal food. Through extensive review of the literature, laboratory sampling and analysis, and comparison of the results of surveillance and sampling in previous years, the following possible carry-over scenarios were obtained. See Table 4

Comprehensive Judgment
The use of food additives must be carried out in strict accordance with GB2760, but when determining the use of food additives in food, the situation of food ingredient carry-over or background carry-over should be taken into consideration, and combined with the scope of use and the use amount of food additives permitted to be used in food end-products and each ingredient of the ingredient list, or the value of the background amount of a class of food raw materials to carry out a comprehensive judgment. See Figure 1

Summary [6]
For manufacturers, they should focus on the quality of food ingredients or excipients, especially on the important basic data such as which food additives are used in the ingredients or excipients and how much they are used, so that they have a clear idea. In addition, in order to allow the regulatory authorities or inspection agencies in the detection of food additives detected in the case of food testing, can judge the application of scientific and reasonable use of the principle of bringing in, the production enterprise in the product ingredient information should be truthfully labeled, and when necessary, to provide a true and reliable type of ingredients in the production process (name), the ratio of the information as well as ingredients in the level of detection of the additives in the data to prove that the risk of detection in the full combination of the This is particularly important for risk identification to fully combine the information on raw and auxiliary materials to comprehensively analyze the causes of risk.
For inspection organizations, when an additive that is not allowed to be used is detected in a food, it is necessary to fully combine the information on the ingredients, fully consider the possibility that it may be reasonably brought in by the ingredients, and consider whether it may have played a specific role in conjunction with the level of detection. At the same time, in the test report to reflect the consideration of the principle of carry-over, the situation will be clearly explained, can be used in similar terms, such as “test results have been accounted for the reasonable carry-over of ingredients” and so on.
For the regulatory authorities, in the daily supervision of enterprises should be required to strengthen the supply of invoices, material use records, labeling specifications, and so on, thus accounting for the balance of materials, truthfully tracing the ingredients and ratios of information; in the test conclusions of the objections to the processing and risk identification, should be fully combined with the daily production of production enterprises in the batch production records, supply records, raw materials and auxiliary materials, inspection reports and other key clues to information, and thus discover the causes of risk! and to be scientific judgment and disposal.